ML20132A560
| ML20132A560 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/08/1984 |
| From: | Conlon T, Miller W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20132A500 | List: |
| References | |
| 50-327-84-31, 50-328-84-31, NUDOCS 8507230091 | |
| Download: ML20132A560 (9) | |
See also: IR 05000327/1984031
Text
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Report Nos.: 50-327/84-31 and 50-328/84-31
Licensee: Tennessee Valley Authority
500A Chestnut Street
Chattanooga, TN 37401
Docket Nos.: 50-327 and 50-328
License Nos.:
Facility Name:
Sequoyah
Inspection Condu ted:
ctob
1984
O' Eb
Inspector
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W. H. Miller, Jr.
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Date Signed
Approved by
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T. E. Conlon, Section Chief
Date Signed
Engineering Branch
Division of Reactor Safety
SUAMARY
Scope:
This routine, unannounced inspection entailed 27 inspector-hours on site
in the areas of fire protection / prevention, followup on the licensee's
compensatory actions regarding Confirmation of Action Letter on Appendix R fire
protection' discrepancies, and review of corrective actions on previously
identified NRC and licensee identified items.
Results:
Of the areas inspected, two apparent violations were found (all fire
brigade members are not respirator qualified - paragraph 6.a. and no maintenance
program provided for fire protection strainers - paragraph 6.c.
One apparent
deviation was Lfound (fire protection system containment isolation valves are not
provided with statu lights in the main control room - paragraph 3.e).
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8507230091 841114
ADOCK 05000327
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REPORT DETAILS
1.
Licensee Employees Contacted
J. Alexander, Shift Engineer
- W. H. Baker, Fire Protection Engineer
- J. Blankenship, Information Officer
- L. Bush, Operations Group
- S. Butler, QA Supervisor.
- M. R. Cooper, Compliance Engineer
- D. E. Crawley, Health Physics Supervisor
- J. T. Dills, Jr., Asst. Health Physicist
- V. L. Dudley, Fire Protection Engineer
- R. W. Fortenbury, Engineering Section Supervisor
- M. R. Harding, Engineering Group Supervisor
- G. B. Kirk, Compliance Engineer
- J. B. Krell, Plant Superintendent (Maintenance)
- J. D. McCamy, Engineering and Testing
R. Moore, DQA/QAB
- L.M. Nobles, Superintendent (0&E)
- R. W. Olson, Modification Manager
- D. L. Paul, Senior Engineer, Site Service
- M. A. Purcell, Mechanical Engineer
- J. H. Sullivan, Appendix R. Project Manager
- J. M. Qualls, Operations
- P. R. Wallace, Plant Manaser
- J. E. Wills, Licensing Engineer
- G. G. Wilson, Assistant Ops Supervisor
NRC Resident Inspector
E. Ford
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on October 26, 1984, with
.those persons indicated in paragraph 1 above. The licensee acknowledged the
following inspection findings:
a.
Inspector Followup Item (327 and 328/84-31-01), Fire Detectors Over
ERCW Pumps are Not Included in the Technical Specifications - paragraph
3.a.
b.
Deviation Item (327 and 328/84-31-02), Fire Protection System
Containment Isolation Valves Are Not Provided with Status Lights in the
Main Control Room - paragraph 3.e.
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c.
Violation Item (327 and 328/84-31-03), All Fire Brigade Members Are Not
Respirator Qualified - paragraph 6.a.
d.
Violation item (327 and 328/84-31-04), No Maintenance Program Provided
for Fire Protection System Strainers - paragraph 6.c.
3.
Licensee Action on Previous Enforcement Matters
a.
(Closed) Deviation Item (327/81-14-03), Fire Detection Is Not Provided
Over ERCW Pumps.
Fixed temperature type fire detectors have been
provided over each ERCW pump.
These detectors are not included in
Technical Specifications as required.
This is identified as Inspector
Followup Item (327 and 328/84-31-01), Fire Detectors Over ERCW Pumps
are not Included in the Technical Specifications, and will be reviewed
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during a subsequent NRC inspection.
b.
(Closed) Unresolved Item (328/81-14-03), Fire Detection is Not Provided
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Over ERCW Pumps. Refer to abw e item 3.a.
c.
(0 pen) Deviation Item (327/80-10-01), Substandard Fire Protection
Administrative Procedures.
As previously reported in Report Nos.
327/80-17 and 328/80-10, the licensee revised the plant procedures to
comply with the NRC guidelines for fire brigade training and drills.
Subsequently, procedure PHYSI 13, Section 4.5.1, has been revised to
require wood used in safety-related areas of the plant to be of the
pressure fire retardant type unless an exemption is granted by the
plant safety staff for use of other types of materials.
This appears
to meet the intent of the NRC guidelines.
Fire fighting procedures for
all safety-related areas have not yet been prepared.
The licensee
stated that approximately five procedures for safety-related areas and
20 for nonsafety-related areas remain to be prepared. This item is to
. remain open until these procedures are prepared.
d.
(Closed)DeviationItem(327/80-10-02), Substandard Supervision of Fire
Protection Control Valves.
The licensee has established Procedure
SI 654, Fire Protection Header Valve Seal Inspection (Weekly), and is
inspecting the control valves to the automatic sprinkler systems
weekly.
These valves are maintained sealed in the correct alignment.
This arrangement meets the applicable NFPA criterion and is acceptable,
but does not meet the TVA commitments to lock the valves in the open
position.
The commitments should be reviewed and revised as required.
However, for Region II's inspection program, this item is closed,
e.
(Closed) Unresolved Item (327/80-10-07), Supervision of Containment
Isolation Fire Protection Valves.
TVA has taken no corrective action
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on this item.
FSAR, Section 6.2.4.2.2, states that the safeguard
position of automatic containment isolation valves is indicated by
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status lights in the main control room.
The position of the contain-
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ment isolation valves in the fire protection piping which penetrates
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the containment is not provided with status lights in the control room.
Therefore, this unresolved item is closed, but this FSAR discrepancy
which is applicable to both units is identified as Deviation Item (327
and 328/84-31-02), Fire Protection System Containment Isolation Valves
Are Not Provided With Status Lights in the Main Control Room.
4.
Unresolved Items
Unresolved items were not identified during this inspection.
5.
Review of Appendix R Confirmation of Action Commitments (92703)
following the NRC Reg (ion II July16 - 20, 1984, 10 CFR 50 Appendix R inspec-
,
tion of Watts Bar
Report Nos. 50-390/84-55 and 50-391/84-43), TVA
identified a number of cable interaction deficiencies at Sequoyah.
On
August 10, 1984, NRC Region II issued a Confirmation of Action Letter to TVA
identifying the action to be taken by TVA to implement a complete review of
the Appendix R program at Sequoyah, the compensatory measures to be
established for the identified deficiencies, and an established
time
schedule for submission of status reports.
TVA's review continues to identify Appendix R deficiencies.
The final TVA
report is scheduled to be submitted to Region II prior to January 1,1985,
at which time the appropriate enforcement action will be determined.
This inspection reviewed the following deficiencies as identified by TVA's
report dated October 15, 1984, and the compensatory action taken for the
deficiencies:
a.
TVA Appendix R Review Team
TVA has established a team consisting of 51 (38 full-time and 13 part-
time) engineers, technicians, and operational personnel to reevaluate
Design Engineering (ENDES) pliance with Appendix R requirements.
the Sequoyah plant for com
has 11 people on site and 27 in the design
office in Knoxville and operations has assigned 13 personnel to assist
in the site review. The team appears well managed, organized and is on
schedule to meet the established review completion schedule.
b.
Fire Shutdown Logic Diagram
The shutdown logic diagram continues to be revised to reflect the
actual "as built" plant conditions and systems currently considered to
be required for safe shutdown.
This item wiil be reviewed during a
future NRC inspection,
c.
Cable Interaction Evaluation
As of October 15, 1984, TVA has produced over 90 drawings which
indicate the cable routing in the plant.
Approximately 75% of these
drawings had been field verified.
Field verification is scheduled to
be completed by October 29, 1984.
A total of 34 cable interactions
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which violate Appendix R,Section III.G.2 criteria have been identified
by TVA.
The NRC inspector toured each of these interaction areas and
noted that all of these interactions are in areas provided with
automatic sprinkler protection and a fire detection system, except
interactions above the ceiling of the counting room and RWST pipe
tunnel in Unit I which consist of a bank of 36 conduits, and inter-
actions in the Units 1 and 2 pipe chases at 690' elevation. However, a
temporary temperature monitor system has been installed in the Units 1
and 2 pipe chases and ERCW pipe tunnel (Refer to paragraph 5.g below).
The installed sprinkler systems have some minor obstructions from
cable trays, ducts, hangers, structural support, etc.
The more
critical obstructions are located on the 714' elevation of the
auxiliary building.
The inspector suggested that TVA review the
entire sprinkler system installation and verify that the systems
would meet the requirements of Appendix R,Section III.G.,
i.e.,
the system must be capable of assuring that in the event of a fire
et least one train of hot shutdown system is maintained free of fire
damage.
d.
Associated Circuit Analysis
The associatet circuit analysis is being conducted in TVA's Knoxville
design office
This analysis is approximately 55 percent complete for
auxiliary powti cables and 95 percent complete for control power
cables.
The analysis is required to be completed and submitted to NRC
Region II by December 21, 1984. A review of this analysis will be made
by the NRC during a subsequent NRC inspection.
e.
Reactor Coolant Pump 011 Collection
The oil collection systems for the reactor coolant pumps were
identified by TVA as being of insufficient capacity to hold the oil
resulting from the largest spill due to a single failure.
Modifica-
tions which had been made since the initial design of the system to
satisfy other commitments and safety issues had reduced the volume
available for oil collection.
TVA's evaluation indicated that the
drain piping system plus a portion of the collection sump would be
sufficient to hold the oil from a single failure if sufficient capacity
was available for oil collection.
Therefore, TVA has revised
annunciator procedure No. 501-55-1MS, Annunciator Response, (Change No.
84-1475) and issued a " Night Order" to require the operator to verify
that the reactor building pocket sump is maintained at less than 45%
full in the event of a high or low level alann in either the upper or
lower bearing oil reservoir for the reactor coolant pumps.
The
inspector verified that these procedures were properly filed within
the control room.
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The present arrangement of the oil collection system for the reactor
coolant pumps does not meet the requirements of Appendix R,
Section III.0 since the drainage system will not handle an oil break
from all of the lubrication systems simultaneously following a safe
shutdown earthquake.
This discrepancy requircs a formal deviation
request.
NRC Region !! will review this system in detail during a
subsequent inspection.
f.
TVA has identified a number of additional plant areas where operator
action is required to bring the plant to hot shutdown.
These
additional areas are not provided with the 8-hour emergency lighting
units required by Appendix R.Section III.J.
Approximately 75
additional 8-hour type lighting units will be required. Also, some of
the existing lighting units were found by TVA to have 25 watt lamps in
lieu of 10 watt lamps which are needed for the units to provide eight
hours of illumination.
The correct lamps are to be instelled for these
units. As an interim measure, TVA has supplied 12 portable lanterns to
the operation staff for use in the event of the failure of the normal
and other emergency lighting systems.
The inspector verified that
these portable lanterns were provided.
Nine lanterns were provided in
a cabinet adjacent to the auxiliary control room and three lanterns
were in a cabinet adjacent to the shift engineer's office in the
control building.
Additional flashlights and batteries were also
provided.
g.
Firewatch
Following identification of the Appendix R.
Section III.G, cable
interaction discrepancies, the licensee initiated three roving and one
fixed firewatch per shift to provide continued sur eillance of selected
areas in the auxiliary, control, turbine, diesel generator, and
essential raw cooling water pumping station buildings in which the
interaction discrepancies had been identified.
Each roving firewatch
is required to cover his assigned areas once each hour per shift.
Checklists have been provided to document the time each room or area
is visited.
The one stationary firewatch monitors the temperature
indicators provided for the two pipe chases and ERCW pipe tunnel. TVA
has implemented a procedure which identifies the firewatch duties and
assignments.
The inspector verified that all of the current personnel assigned
firewatch duties had completed the required training, appropriate
firewatch records were provided and that the program was being imple-
mented.
No discrepancies were noted, except the firewatch checklists
for two shifts, August 13 (2300 to 0700) and September 24, (0700 to
1500) 1984, were not available.
However, the daily control room
journal log indicated that the firewatch duties were performed for
these dates.
This problem occurred following the initial implementa-
tion of this firewatch program.
At that time, a portion of the fire
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watch personnel was supplied by two management groups. To improve the
management of this program, TVA assigned all firewatch personnel under
the supervision of the operations supervisor.
Presently, this program
appears to be satisfactorily implemented.
h.
QA Program
The licensee stated that all modifications accomplished as a result of
this Appendix R reevaluation are to be accomplished under the normal
operations QA/QC program.
The inspector reviewed work plan 11192
(ECN-L6209) for the installation of some of the fire barriers and
verified that appropriate OA/QC hold points were designated.
Within the areas examined, no violations or deviations were identified.
However, as noted above, enforcement action on the licensee identified items
is being deferred pending completion of TVA's evaluation.
6.
Fire Protection / Prevention Program Implementation (64704)
A review was made of the following fire protection features to verify that
the licensee was implementing a program for fire protection and prevention
that was in conformance with NRC requirements, consnitments to the NRC, and
site procedures:
a.
Fire Brigade
The fire brigade is composed of personnel from the operations group.
The team leader is an assistant shift engineer and the brigade members
are auxiliary unit operators.
There are 16 designated brigade leaders
and 79 members.
The training, drill and medical review records for
four team leaders and ten members were reviewed to verify that these
personnel had attended the basic and/or leadership training, quarterly
classroom training, two drills within the past year, medical review
within the past year, and were respirator qualified.
From the record
data reviewed, the only discrepancy noted was that four of the brigade
members were not respirator qualified. One member had never received a
respirator fit test, one member was five months overdue for a whole
body count, and two were slightly over due (24 and 4 days) for medical
review.
A cursory document review indicated that a number of other fire brigade
members were also not respirator qualified.
Radiation Control
Instruction RCI-14,Section V.A. states that respirator protection is
required for conditions involving airborne contamination and that the
workers must have a current whole body count, respiratory fit and
training and current medical review.
Technical Specification, Section 6.8.1.a. requires written proccudres to be established, implemented and
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maintained covering the applicable procedures listed in Appendix A of
This guide requires procedures for radiation
protection.
The failure of brigade members to meet the respiratory
qualification program is identified as Violation Item (327 and 328/
84-31-03), All Fire Brigade Members are Not Respirator Qualified.
b.
Fire Brigade Equipment
The fire brigade equipment is stored in a locked storage area on 706'
elevation of the service building which is readily accessible to the
auxiliary and control buildings.
A total of ten self contained
breathing apparatus with ten spare cylinders, ten sets of turnout gear
(boots, helmets, coats, gloves, etc.), hand lights, fire hose, nozzles,
two portable exhaust fans and miscellaneous equipment were provided.
An equipment trailer with additional fire hose, extinguishers and
miscellaneous equipment is located outside the plant structure near the
main security entrance gate.
An additional 82 breathing apparatus and
72 spare cylinders are available to the fire brigade from health
physics, which is adequate to meet the required six-hour supply for the
brigade. The fire brigade equipment appeared satisfactorily maintained,
c.
Fire Protection Systems
The completed surveillance inspection and test records for the
following systems at indicted dates were reviewed to verify that these
systems were inspected and tested within the frequency established by
the Technical Specifications:
(1) SI 167, Fire Header Valve Lineup Inspection (Monthly)
January 5 through September 15, 1984
(2) SI172,FireSystemTestableValveCycling(12 months)
August 10, 1982 through August 24, 1984
(3) SI 173, Fire System Nontestable Valve Cycling (18 months)
July 29, 1983 through October 13, 1984
(4) SI 174, Fire System Sprinkler System Testable Valves (12 months)
August 9, 1983 through August 8, 1984
(5) SI 176
Fire Suppression Water Sprinkler System Functional Test
(18 months)
September 12, 1982 through March 2, 1984
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(6) SI 180, Fire Pump Start Test
January 9 through September 15, 1984.
Pump 1AA was removed from
service on July 18, 1984, for major repairs.
Pump was restored to
service on August 24, 1984.
(7) SI 190, Fire Hose Inventory (Monthly)
January 13, 1984 through October 15, 1984
(8) SI 234.2, Fire Detection System - 714' of Auxiliary Building,
Intake Pumping Station and ERCW Pumping Structure (6 months)
July 2, 1983 through July 16, 1984
In reviewing the licensee's surveillance inspection and test program
for the fire protection automatic water spray and sprinkler system,
it was noted that the strainers in the supply piping to these systems
were not included in
periodic maintenance inspection and cleaning
programs required by NFPA-15, Water Spray Fixed Systems for Fire
Protection, Section 6012 (1973 Edition).
FSAR, Section 9.5.1.4,
states that fixed water suppression systems are periodically tested
in accordance with the applicable NFPA code requirements to ensure
operability and inspected at regular intervals to ensure that all
equipment is in good operating condition.
Technical Specification, Section 6.8.1.f
requires written procedures to be established, imple-
mented and maintained for the fire protection program implementation.
The lack of a maintenance program for these strainers is identified as
Violation Item (327 and 328/84-31-04), No Maintenance Program Provided
for Fire Protection System Strainers.
d.
Annual Full-Scale Fire Drill With Offsite Fire Fighting Organization
The annual full-scale fire drill was conducted on November 3,1983,
with the site brigade and the Soddy-Daisy Fire Department. A total of
approximately 19 site fire brigade and 15 fire department personnel
participated.
The inspector reviewed the drill report and evaluation
and had no further questions.
c.
Plant Tour
During the plant tour to review the Appendix R cable interaction
discrepancies, the plant's fire prevention and protection features were
observed.
As a whole, the housekeeping and control of combustible and
flammable liquids and gases within the areas toured were satisfactory.
A welding operation was noted in which an approved " hot work" permit
had been issued and appropriate safety precautions were being observed.
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The fire protection systems within the areas toured were found to be in
service and appeared to be satisfactorily maintained.
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Within the areas examined, except as noted above, no additional violations
or deviations were identified.